Ten90 Solutions LLC

Something was bugging me...

...about the Hoboken collision and I couldn't quite put my finger on it, until "it" woke me up this morning:  What about the alertness device on the cab car?

What about it? There's at least a 38 second interval from the time the locomotive engineer went to throttle "4" and the train accelerated to 20 mph to the time the engineer must have become cognizant of the danger,  throttled off and placed the train in emergency braking. Shouldn't the alerter have sounded and required the engineer to take some action?

Those of you with a memory as good as mine (which isn't much of an achievement) will recall that after the Metro-North overspeed derailment at Spuyten Duyvil a bit of a fuss was made over the fact that the Bombardier cab cars were not equipped with electronic alertness devices, utilizing only "dead-man" pedals.  There was the usual speculation by the usual speculators that an alerter might have been able to compel the locomotive engineer's attention to the imminent danger.  So...  

So the Comet cab cars utilized on NJT trains are equipped with electronic alerters, and 38 seconds is a long time and shouldn't the alerter have sounded, and and and........

And nothing.  The installation and function of alerters is required by 49 CFR 229.140 which specifies that the timing cycle, the intervals between alerts, be within 10 seconds of the time derived from the formula 2400 divided by the speed of the train in miles per hour.  So if the train is operating at 80 mph, the alerts have to occur every 40 to 20 seconds.  

For locomotives operating at speeds below 20 mph, the interval must fall between 110 and 130 seconds.  So accelerating to 20 mph, for 38 seconds, with the locomotive engineer fast asleep, and the end of track 800 feet away?  The alerter is of no use, and no value.  Literally.  

FRA establishes minimum standards for compliance, and the minimum standards may not have the slightest relation to the actual risk that the standard is supposed to ameliorate.  In the case of electronic alerters, the assumption behind the timing cycle is that the higher the speed, the greater the risk.  

The experience behind the assumption?  The experience of long-distance long haul passenger trains and freight trains operating over track not equipped with automatic cab signals and automatic speed control systems.  Then, because the speed of the train is not subject to any enforcement separate from the locomotive engineer's "will," we think we can work around that fundamental vulnerability, that single source of failure,  by making the fundamental vulnerability, that single source of failure, more alert.  

In practice, the theory, practice,and assumptions don't apply to commuter train operations where cab signals and speed control govern train movement.  Under those conditions, the greatest risk to safe train operations exists in the slow speed operations-- in the low speed violation of a stop signal; in the low speed violation of restricted speed requirements-- precisely those areas of enforcement outside the "reach" of the older automatic speed control systems.  

Railroads, including commuter railroads, are so intent  on satisfying the "minimum standard" for compliance, the actual vulnerabilities to safe train operations drop away from discussion and action.  

When the RFPs, design specs, etc go out for the purchase of locomotives or cab cars, you can be certain every document will have the following spec:  "Alerters:  each locomotive will be equipped with an alertness device that meets all the requirements listed in 49 CFR 229.140."

I don't know of a single operating officer at any level authority who ever said that he or she actually needed FRA to tell him or her what to do.  We all, and always, have said, "the day I need FRA to tell me how to run a safe railroad is the day I resign my position."  But when it comes to actually insisting on a performance specification, then, for some strange reason, doing what the FRA tells us to do, meeting the minimum standard,  is supposed  to be more than enough.  

We accept that "minimum standard" as an effective substitute for establishing continuous speed enforcement from X velocity to zero velocity under all circumstances.

My recommendation is that we do away with "minimum standards for compliance;" that we not avail ourselves of FRA's minimums.  For example, we should not avail ourselves of FRA's minimal requirement necessary to win mainlne track exemptions in passenger terminals; that is to say that speed be capped at 20 mph.

Rather, we should enforce terminal operating speeds at 10 mph and set a zero mph target at the end of every platform track.  Of course, we set the target itself far enough beyond the end of track so as to get the maximum usable length of the track for trains, but that represents no risk to safety as the braking curve enforced by the zero velocity target will prevent derailment.  We positively enforce the stop required at the end of the track.

Bumping blocks?  Save your money.  Don't buy them, or buy styrofoam blocks and have them carved and painted to look like bumping blocks.

Then use the money you won't spend on bumping blocks to equip these hunks of styrofoam with WIUs that will set a zero velocity target for trains entering the track.  

Then with the money you save by not buying bumping blocks, but by enforcing zero velocity; the money you save from not clearing wrecks, from not derailing/rerailing trains by actually controlling train speed, we can buy more equipment, without alerters, and run more trains, at more than a minimum standard.  

David Schanoes

September24, 2017

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